Privacy Policy

Data Protection & Patient Privacy Policy

Version: 2018.1
Dated: 25 May 2018

Table of Contents

1. Who we are
2. Why we collect personal information about you
3. What is our legal basis for processing your personal information
4. What personal information do we need to collect about you and how do we obtain it
5. What do we do with your personal information
6. What we may do with your personal information
7. Who do we share your personal information with and why
8. How we maintain your records
9. What are your rights
10. Who is the Practice Information Governance Lead
11. Who is the Data Protection Officer
12. How to contact the Information Commissioners Office

Introduction

This Privacy Notice explains what information we collect about you, how
we store this information, how long we retain it and with whom and for
which legal purpose we may share it.

Island Medical Centre also publishes a number of specific notices which are available at the bottom of this page.

1. Who we are?

Island Medical Centre employs more than 60 staff and operates from their main surgery at 14, Gloucester Street, St Helier and has branches in Grouville, St Brelade and St John.

Our Practice is registered with the Office of the Information Commissioner (OICJ) to process personal and special categories of information under the Data Protection (Jersey) Law 2018 and our registration number is 16722.

This website is owned by Island Medical Centre. Webreality provides a managed hosting service for the website, with Amazon AWS as the datacentre provider. Details of their Privacy Policy can be found on their individual websites: www.webreality.co.uk/privacy-policy and https://aws.amazon.com/privacy/.

2. Why we collect personal information about you?

Our clinical and administration team caring for you will need to collect and maintain information about your health, treatment and care, so that you can be given the best possible healthcare from us.

This personal information may be held in a variety of formats, including paper records, electronically on computer systems, in pictures, video or audio files.

3. What is our legal basis for processing your personal information?

Any personal information we hold about you is processed for the purposes of ‘Employment and Social Fields’ (Article 8) ‘Medical Purposes’ (Article 15) and ‘Public Health’ (Article 16) of the Data Protection (Jersey) Law 2018.

For further information on this legislation please visit: https://oicjersey.org/data-protection-new-law/

4. What personal information do we need to collect about you and how do we obtain it?

Personal information about you is collected in a number of ways. This can be from registration forms, referral details from our clinical or administration team, other third party healthcare providers or hospitals,
directly from you or your authorised representative.

We will likely hold the following basic personal information about you: your name, address (including correspondence), telephone numbers, date of birth, emergency contact and next of kin contacts, etc. We might also hold your email address, marital status, occupation, residency status, place of birth and preferred name or previous name(s).

In addition to the above, we may hold sensitive personal information about you which may include:

• Notes and reports about your health, treatment and care, including:
  • your medical conditions
  • results of investigations, such as x-rays and laboratory tests
  • future care you may need
  • personal information from people who care for and know you,
    such as relatives and health or social care professionals
  • other personal information such as smoking status, alcohol
    intake and any disabilities
  • Your religion and ethnic origin
  • Your identified gender or sexual orientation
  • Whether or not you are subject to any protection orders
    regarding your health, wellbeing and human rights (Safeguarding status).

It is important for us to have a complete picture of you as this will assist
staff to deliver appropriate treatment and care plans in accordance with
your needs.

5. What do we do with your personal information?

Your records are used to directly, manage and deliver healthcare to you to ensure that:

• The staff involved in your care have accurate and up to date
  information to assess and advise on the most appropriate care for
  you.
• Staff have the information they need to be able to assess and
  improve the quality and type of care you receive.
• Appropriate information is available if you see another healthcare
  professional, or are referred to a specialist or another part of the
  Jersey Health Service, social care or other health provider in Jersey,
  UK or elsewhere.

6. What we may do with your personal information?

The personal information we collect about you may also be used to:

• Remind you about your appointments and send you relevant
  correspondence.
• Review the care we provide to ensure it is of the highest standard
  and quality, e.g. through audit or service improvement;
• Support the funding of your care, e.g. with commissioning
  organisations;
• Prepare statistics on Primary Care performance to meet the needs of
  the population or for the Health Department and or other regulatory
  bodies;
• Help to train and educate healthcare professionals;
• Report and investigate complaints, claims and untoward incidents;
• Report events to the appropriate authorities when we are required
  to do so by law;
• Contact you with regards to patient satisfaction surveys relating to
  services you have used within our organisation so as to further
  improve our services to patients.

Where possible, we will always look to anonymise/pseudonymise your
personal information so as to protect patient confidentiality, unless there is a legal basis that permits us to use it and we will only use/share the
minimum information necessary.

7. Who do we share your personal information with and why?

We may need to share relevant personal information with other healthcare organisations.

For example, we may share your information for healthcare purposes with health authorities such as Jersey Health Department, Social Security Department, NHS UK, Out of Hours Service, other general practitioners (GPs), ambulance services, private consultants, primary or secondary care service providers, etc.

We will also share information with other parts of the Jersey Health Department and those contracted to provide services to the Health Department in order to support your healthcare needs.

We may need to share information from your health records with other
non-Health Department organisations from which you elect to or are also
receiving care from, such as Social Services, private consultants, secondary care providers or private care homes. However, we will not disclose any health information to third parties without your explicit consent unless there are circumstances, such as when the health or safety of others is at risk or where current legislation permits or requires it.

There are occasions where the Practice may be required by law to share
information provided to us with other bodies responsible for auditing or
administering public funds, in order to prevent and detect fraud.
There may also be situations where we are under a duty to share your
information, due to a legal requirement. This includes, but is not limited to, disclosure under a court order, sharing with the Jersey Primary Care
Governance Team for inspection purposes, the police for the prevention or detection of crime or where there is an overriding public interest to
prevent abuse or serious harm to others and other public bodies (e.g.
Social Security for the misuse of public funds in order to prevent and
detect fraud).

For any request to transfer your data internationally outside Jersey or the
UK/EU, we will make sure that an adequate level of protection is satisfied
before the transfer The Practice is required to protect your personal information, inform you of how your personal information will be used, and allow you to decide if and how your personal information can be shared. Personal information you provide to the Practice in confidence will only be used for the purposes explained to you and to which you have consented. Unless there are exceptional circumstances, such as when the health or safety of others is at risk, where the law requires it or there is an overriding public interest to do so.

Where there is cause to do this, the Practice will always do its best to
notify you of this sharing.

We will not share any of your personal data with any third parties for any
purposes, subject to the following exceptions. In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

If any of your personal data is transferred to a third party, as described
above, we will take steps to ensure that your personal data is handled
safely, securely, and in accordance with your rights, our obligations, and
the third party’s obligations under the law.

8. How we maintain your records?

Your personal information is held in both paper and electronic forms for
specified periods of time as set out in the Information Government
Alliance Records Management Code of Practice for Health and Social Care.

Whilst this is UK legislation for NHS Providers, it is used in Jersey as a ‘Best Practice Solution’ in the void of our own similar procedures. We hold and process your information in accordance with the Data Protection (Jersey) Law 2018 and where appropriate the General Data Protection Regulation. In addition, everyone working for our Practice must comply with the Contractual Duty of Confidentiality and various national and professional standards and requirements.

We have a duty to:

• maintain full and accurate records of the care we provide to you.
• keep records about you confidential and secure.
• provide information in a format that is accessible to you.

Use of Email/SMS Text/Other Electronic Communications:
Some services in the Practice provide the option to communicate with patients via email, SMS text or other electronic communications. Please be aware that the Practice cannot guarantee the security of this information whilst in transit, and by requesting this service you are accepting this risk.

9. What are your rights?

If we need to use your personal information for any reasons beyond those stated above, we will discuss this with you and ask for your explicit
consent.

The Data Protection (Jersey) Law 2018 gives you certain rights,
including the right to:

• Request access to the personal data we hold about you, e.g. in health records. The way in which you can access your own health records is further explained in our “patient access to medical records policy and request form” which will soon be on our website: https://islandmedicalcentre.com/
• Request the correction of inaccurate or incomplete information
  recorded in our health records, subject to certain safeguards.
• Refuse/withdraw consent to the sharing of your health records: Under the Data Protection (Jersey) Law 2018, we are authorised for the purposes of ‘Employment and Social Fields’ (Article 8) ‘Medical Purposes’ (Article 15) and ‘Public Health’ (Article 16). Your consent will only be required if we intend to share your health records beyond these purposes, as explained above (e.g. research). Any consent form you will be asked to sign will give you the option to ‘refuse’ consent and will explain how you can ‘withdraw’ any given consent at a later time. The consent form will also warn you about the possible consequences of such refusal/withdrawal.
• Request your personal information to be transferred to other
  providers on certain occasions.
• Object to the use of your personal information: In certain
  circumstances you may also have the right to ‘object’ to the
  processing (i.e. sharing) of your information where the sharing would
  be for a purpose beyond your care and treatment (e.g. as part of a
  local data sharing initiative).
• We will always try to keep your information confidential and only
  share information when absolutely necessary.

If you wish to raise a complaint on how we have handled your personal
data, you can contact our Data Protection Officer who will investigate the
matter and respond to you accordingly where appropriate.

10. Who is the Practice Information Governance Lead

Please contact:

Dr J Newstead, (General Practitioner)

Island Medical Centre
14 Gloucester Street
St Helier
Jersey
JE2 3QR

Email: info@imc.gpnet.je

11. Who is the Data Protection Officer?

Please contact:

Mr C A Sprent, (Practice Manager)

Mrs J Coates RN, RM, BSc (Hons), (Clinical Manager)

Island Medical Centre14 Gloucester Street
St Helier
Jersey
JE2 3QR

Email: info@imc.gpnet.je

Telephone: 01534 516151

12. How to contact the Information Commissioners Office

The Jersey Office of the Information Commissioner (JOIC) is the body that regulates the Practice under Data Protection and Freedom of Information legislation. https://jerseyoic.org. If you are not satisfied with our response or believe we are processing your personal data not in accordance with the law you can complain to the OIC at:

Office of the Information Commissioner
2nd Floor
Castle Street
St Helier
Jersey
JE2 3BT

Email: enquiries@jerseyoic.org

Telephone:  01534 716530